JUDGMENT

M.S. Sonak, J. - Heard Mr. Hanumant Naik for the Petitioners and Ms. Amira Razaq for the Respondents.

2. Rule. With the consent of and at the request of the learned counsel for the parties, the Rule is made returnable forthwith. Even otherwise, the learned counsel for the parties had requested that this petition be disposed of finally at the stage of admission itself, since, the pleadings were complete.

3. The challenge in this petition is to the notices dated 24.03.2017 and 31.03.2017 issued under Section 148 of the Income Tax Act (said Act) seeking to reopen the assessment for the Assessment Year 2010-2011.

4. Ms. Razaq, at the outset, submitted that the petition is premature insofar as petitioner no.2 is concerned. She submitted that the procedure prescribed by the Hon'ble Supreme Court in G.K.N. Driveshaft (India) Limited v. Income Tax Officer 259 ITR 19 was never followed insofar as the petitioner no.2 is concerned.

5. Technically, Ms. Razaq may have a point, but in the peculiar facts of the present case, there is no point in relegating petitioner no.2 to follow the said procedure. This is because it was even admitted by Ms. Razaq that there is no difference whatsoever, ei